ACC Legislative Conference

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The Centers for Medicare and Medicaid Services (CMS) on Sept. 8 announced it will provide clinicians with numerous options for participation in the new Quality Payment Program, initiated by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), in 2017 to help them avoid a negative payment adjustment in 2019. CMS made this decision, which comes ahead of the release of the final MACRA rule expected by November, after receiving feedback from stakeholders across the country who expressed concern with the Jan. 1, 2017, reporting period start date outlined in the proposed rule.

"Universally, the clinician community wants a system that begins and ends with what's right for the patient. We heard from physicians and other clinicians on how technology can help with patient care and how excessive reporting can distract from patient care; how new programs like medical homes can be encouraged; and the unique issues facing small and rural non-hospital-based physicians," said Acting Administrator of CMS Andy Slavitt in a blog post.

Four options are available for Quality Payment Program participation in 2017:

Test the Quality Payment Program: Report a minimum amount of data in at least one of the categories (i.e., one Quality measure, one Improvement Activity, or all five required Advancing Care Information measures) to avoid a negative payment adjustment in 2019.

Participate For Part of the Calendar Year: Report a minimum amount of data in at least one of the categories (i.e., one Quality measure, one Improvement Activity, or all five required Advancing Care Information measures) to avoid a negative payment adjustment in 2019.

Participate For the Full Calendar Year: Submit data across all Merit-Based Incentive Payment System categories covering the full year reporting period (starting Jan. 1, 2017) for a potential modest positive payment adjustment in 2019.

Participate in an Advanced Alternative Payment Model (APM): Participate in an recognized Advanced APM and meet the patient or payment threshold in 2017 to receive a 5 percent incentive payment on Medicare Part B payments in 2019.

In its comments regarding the proposed MACRA rule, the College urged CMS to initiate a "hold-harmless" year and/or phase in requirements over time if clinicians experience widespread difficulty transitioning to the new reporting structure. The ACC is pleased that CMS will provide flexibility for participation in the first year of the program.

CMS will elaborate on the 2017 program options and other MACRA provisions in the final rule.

While on Capitol Hill next week during the ACC's 2016 Legislative Conference, ACC members will underscore the importance of a "hold harmless" year and encourage Congress to exercise careful oversight of MACRA implementation to ensure CMS interfaces with medical societies and practices to effectively manage the transition.